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Theodore F. Monroe

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February 17, 2017

Acquirer and Third-Party SAR Obligations for Transaction Laundering

Suspicious Activity Reporting (“SAR”) forms the cornerstone of the Bank Secrecy Act (“BSA”) reporting system. Broadly speaking, federal regulations require all banks and financial institutions to […]
February 16, 2017

CNP Series: Lessons from a CNP Fraud Scheme – Part 3

This is the third of four articles that will use the case to examine card-not-present fraud from a legal perspective. Part 1 described the case and […]
February 15, 2017

CNP Series: Lessons from a CNP Fraud Scheme – Part 2

Recently, the criminal case against online merchant Jeremy Johnson in Utah that started back in June 2011 finally came to a close. After more than four […]
February 14, 2017

Lessons from a CNP Fraud Scheme – Part 1

Late last month, the criminal case against Jeremy Johnson that started back in June 2011 finally came to a close. After more than four years of […]
February 13, 2017

Why You Need to Buy Insurance

Payment companies get sued. It is a normal course of business. They plan for it and they are willing to pay for it. The truth is, […]
February 10, 2017

Feds Go After Payment Processors

Department of Justice introduced Operation Choke Point in early 2013 as an enforcement initiative to choke off swindlers’ access to the payments system by targeting the […]
February 9, 2017

Weed Payment Processing

Little more than a year ago, the United States Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued written guidance to banks for extending merchant services to […]